Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00149-WIG Document 136 Filed O3/14/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
FERRON SHORTER JR.
Plaintiff, :
: CIVIL NO; 303 CV 0I49(WIG)
v. 1
HARTFORD FINANCIAL SERVICES GROUP,
INC. and MARYANNE RHODES :
Defendants. 1 MARCH I4, 2005
DEFENDANTS MOTION TO EXTEND TIME TO RESPOND TO I’LAINTIFF’S
MOTION FOR ATTORNEYS FEES, COSTS AND PREJUDGMENT INTEREST
Pursuant to Local Rule '7(in) of this Court, Hartfo1"d Financial Services Group, Inc,.
(“Defendant") respectfuily requests an extension of time of fourteen (I4) days to tile its
Meinorandutn in Opposition to Plaiiitiff s Motion for Attorney’s Fees, Costs and Prejudgnient
Interest dated February 22, 2005. In support of this motion, Defendant states:
i. On February 22, 2005, Plaintiff tiled his Motion for Attorney’s Fees,
Costs and Prejudginent Interest in which Piaintiff sought an award of attorney’s fees and costs
pursuant to 42 U.S.C. § 2000e—2(k) and 28 USC. § l920.
2. Defendant’s response to PIaintift’s Motion for Attorney’s Fees, Costs and
Prejudgnient Interest is due March 15, 2005,
.3. Defendant requests additional time to respond to Plaintiff’s Motion for
Att0tney’s Fees, Costs and Prejudginent Interest to aitow sufficient time for Defendant to
research the legal issues raised by Plaintiff and to evaluate the extensive invoices and other
ORAL ARGUMENT NOT REQUESTED

Case 3:03-cv-00149-WIG Document 136 Filed O3/14/2005 Page 2 of 3
documentation submitted by Plaintiff in support of his motion,. hi support of his motion, Plaintiff
submitted two afiidavits, twenty-six invoices and other docurnentation supporting his claim for
an award of costs Plaintiffs inotion aiso raises novei legal issues in that he requests the
appiication of a multiplier to an award of attorneys’ fees under Title VH,
4. Det’endant’s requested extension of time wiil not unduly delay this niatter.
Under Rule 54(d)(2.)(B) of the Federal Rules and Local Rule li, Plairrtiffs Motion for
Attorney”s Fees was not due until 30 days after the Court’s entry ofjudgnient. The Court has not
yet entered judgntent in this matter,
St The undersigned counsel attempted to contact counsel for Plaintiff,
Attorney Baird, but was unable to ascertain her position as to the granting of this motion.
WHEREFORE, Defendant respectt`ully ntoves for a fourteen day (14) day
extension of time untii March 29, 2005 to tile its Memorandum in Opposition to Plaintift”s
Motion for Attorney’s Fees, Costs and Prejudgznent Interest dated February 2.2, 2005,
DEFENDANT,
HARTFORD FINANCIAL SERVICES
GROUP, INC.,
By: lit"'
ar ret J,. Strange (ct082l2)
.ames F. Shea (ctl6750)
Jac n Lewis LLP
55 Farmington Avenue, Suite 1200
Hartford, CT 06l05
(860) 522—0404
entail: Sil"&l“1gGl'l"1@iE1Ci(SO11l€WlS.,CO1}7
email: sheaj @j£1Cl{SUi1i€WlS,CO1}]
2

Case 3:03-cv-00149-WIG Document 136 Filed O3/14/2005 Page 3 of 3
CERTIFICATION OF SERVICE
This is to ce1·tir`y that a copy ofthe foregoing was sent via first class mai}, postage
prepaid, on this Hlth day of`Mateh 2005, to the foiiowing counsel of record:
Rachel M. Baird
Law Office of Rachel M. Baird
379 Prospect Street
Torrington, CT 06790
Attorney for Plaintiff
David L. Metzger, Esq.
Metzger & Associates
25 Capitol Avenue
Hartford, CT 06106-1707
Attorney for Defendant Maryanne Rhodes
I/I
5 mes Shea
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